UKCA vs CE marking: the current state in Great Britain

Few areas of product compliance have shifted as many times as UKCA versus CE marking in Great Britain. If you read an article, forum post or even an old government page written before late 2024, there is a real chance it describes a deadline that has since been extended or a rule that has since been amended. This post covers the current position as we understand it, with direct links to the primary gov.uk and legislation.gov.uk sources, because this is exactly the kind of area where you should verify against the live guidance rather than trust a fixed date in any article, including this one.

The short version

UKCA (UK Conformity Assessed) marking is Great Britain's post-Brexit equivalent to CE marking, introduced when GB's product rules diverged from the EU's after 1 January 2021. It applies to Great Britain (England, Scotland and Wales) only. Northern Ireland has its own arrangements and continues to use the CE marking (or the UK(NI) marking in specific cases) under its distinct post-Brexit framework.

The critical current fact: since 1 October 2024, the Product Safety and Metrology etc. (Amendment) Regulations 2024 (S.I. 2024/696) extended recognition of the CE marking in Great Britain, allowing businesses to use either UKCA or CE marking for most goods, rather than facing a hard cutover date. This amended earlier sector-specific regulations, including electrical equipment, EMC and radio equipment rules, each of which had its own instrument updated to reflect the extension.

Why this happened

The original plan required a full switch to UKCA by a fixed deadline, which was extended more than once before the government settled, via S.I. 2024/696, on a more durable approach: continued recognition of CE marking for most product categories, alongside an option to use UKCA, rather than a fixed sunset date for CE. This removed the immediate compliance cliff-edge for businesses that had already built CE-compliant supply chains, testing and documentation.

What has not changed: the labelling easement deadline

Separately from the CE recognition question, there is a transitional easement that currently allows the UKCA mark, where used, to be affixed via a label or accompanying document rather than printed directly onto the product or its packaging, plus relief on some importer address details for goods from the EU or Switzerland. Per the current sector regulations (electrical equipment, EMC, radio equipment, RoHS, toys), this easement is due to end on 31 December 2027, after which UKCA (where used) generally has to be on the product itself, subject to the same "too small or by its nature not possible" exceptions long used for CE marking.

A brief timeline, because it keeps changing

Given how much confusion this history has caused, it is worth laying out plainly: Great Britain's post-Brexit product marking regime took effect on 1 January 2021, introducing the UKCA marking as GB's own conformity mark, separate from the EU's CE marking. The government subsequently extended the original CE-recognition transition period more than once as the original deadlines approached, before settling, via the Product Safety and Metrology etc. (Amendment) Regulations 2024, on a more durable approach effective 1 October 2024, allowing continued use of either marking for most goods rather than a further fixed cutover. The remaining scheduled change on the calendar is the 31 December 2027 end of the transitional labelling easement for UKCA, described below. Treat this list as the position at the time of writing, not a permanent settlement; this area has changed direction more than once already.

Northern Ireland is different again

Northern Ireland does not use the UKCA marking in the same way as Great Britain. Under Northern Ireland's distinct post-Brexit arrangements, EU product rules and the CE marking continue to apply for goods placed on the Northern Ireland market, alongside a UK(NI) marking used in specific circumstances. If your supply chain includes Northern Ireland specifically, treat it as a third, separate case rather than assuming either the Great Britain or the EU rules apply automatically; the current gov.uk guidance for Northern Ireland is the place to check the specifics for your product.

Does this mean you can ignore UKCA entirely?

Not necessarily, and this is the part worth checking carefully for your specific product. The extension covers most goods under the "new approach" product safety framework (electrical equipment, EMC, radio equipment, RoHS, toys and similar). Several sectors sit outside this and have always had their own rules: construction products, medical devices, rail products, and marine equipment among them. If your product falls into one of those sectors, do not assume the general CE-recognition extension applies to you without checking the sector-specific guidance directly.

What we recommend doing in practice

Given how much this area has moved, treat any specific date you read, including the ones in this article, as "current as of when it was written" rather than permanent. The reliable approach is:

• Check the current position directly on gov.uk's UKCA marking guidance before making a labelling decision.
• If you already CE mark for the EU market, in most cases you can currently use the same CE-marked product for Great Britain too, without a parallel UKCA process, for the sectors covered by the extension.
• If you are UKCA marking anyway (for export positioning, procurement requirements, or sectors excluded from the extension), keep track of the 31 December 2027 labelling easement deadline for your specific product category.
• Re-check before every major product launch. Policy in this area has changed more than once since 2021, and it can change again.

Our requirements checker reflects the current rules as best we can verify them for each market, with a source link on every fact, but for a decision this consequential, the primary gov.uk guidance is the final word, not us.